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located, and what she was to wear. She would also note whether
she had a callback and whether she was hired. According to the
diary, during 1994 Mrs. Richards had one modeling shoot with
United States Purchasing Corp. (for their catalog) and four
auditions.
Since the acting jobs were sporadic, Mrs. Richards worked as
a clerk, registrar, and secretary for the Palm Springs Unified
School District (PSUSD). Mrs. Richards worked for PSUSD for 29
years and had retired before the year at issue. During 1994,
Mrs. Richards received income from her pension, from the College
of the Desert (a book store where she worked part time), and from
serving as a proctor in administering the Scholastic Aptitude
Test. Mrs. Richards received as compensation $1,574 for the
modeling shoot with United States Purchasing Corp.
On their 1994 Schedule C, petitioners claimed the following
expenses with respect to Mrs. Richards’ actress-model activity:
Expense Amount
Academy players directory (listing) $60
Agent fees 262
Photo session 267
Duplicate photo 231
Must-see shows, plays & movies 480
Miscellaneous 960
Long distance telephone calls 270
Cash telephone calls 56
Total 2,586
As before, we initially must decide whether Mrs. Richards’
actress-model activity was engaged in for profit. Upon reviewing
the entire record, we conclude that during 1994, Mrs. Richards
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